Blanton Coal Co. v. Commissioner
United States Tax Court
Corporation failed to file returns and sought to use its net operating loss carrybacks and/or carryback credits to absorb the tax or underpayment and avoid the delinquency or negligence additions to tax. Held, additions to tax are not affected by carrybacks. Prior case law followed.
1Opinion of the Court
BLANTON COAL COMPANY, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Blanton Coal Co. v. Commissioner
Docket No. 18560-81.
United States Tax Court
T.C. Memo 1984-397; 1984 Tax Ct. Memo LEXIS 283; 48 T.C.M. (CCH) 670; T.C.M. (RIA) 84397;
July 30, 1984.
Corporation failed to file returns and sought to use its net operating loss carrybacks and/or carryback credits to absorb the tax or underpayment and avoid the delinquency or negligence additions to tax. Held, additions to tax are not affected by carrybacks. Prior case law followed.
William A. Watson, for the Petitioner.
Frederick W.…
2Cases cited13 opinions
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
- Thompson v. CommissionerUnited States Tax Court · 1982
- Auerbach Shoe Co. v. CommissionerUnited States Tax Court · 1953
- Auerbach Shoe Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1954
- Robinson's Dairy, Inc. v. CommissionerUnited States Tax Court · 1961
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